A list of lift strut suppliers (updated 12 Dec 2007)

[flyguy]

Re: A list of lift strut suppliers (updated 10 Nov 2007)

Is that article still there, can't find it. Assume General Aviation News--right? Found it, more or less, but I don't see anything on the Ingram "quote."
DC

[jstall]

Re: A list of lift strut suppliers (updated 10 Nov 2007)

This A/D was written to quickly, without enough info to get it in place.

There were not enough suppiers out there at the time and the "Factory
Bandit was the only game in town, to the point of 7 million in sales"

See GAN article

Why would they go to this extreme?" Ingram wrote. "Greed. If the factory wasn't in business they could create an environment very similar to the Piper Cub lift strut Airworthiness Directive. Let's do some math: 3,000 Taylorcrafts, $2,500 for a new set of lift struts equals $7,500,000."

This A/D was issued and constructed for Monitary reasons only, there were no evidence of failures, the Wiley accident was not "struts" but the A/D was written before the investigation was done. Lots of money here, How many are involved is yet to be found but I will assure you the process is starting.

JS

[flyguy]

Re: A list of lift strut suppliers (updated 10 Nov 2007)

Dave,
I think I understand the STC part ok. AF PMA was developed using an existing STC for data. (see my entry above) The UV one was developed using new raw data. Both done under part 21. So much for the STC. So the 337 biz is the only thing that is a question to me. I see the Univair one as being a problem given the information we have presently.
Think we need some more information from UV or the FAA engineer. Question is: does a PMA precede a 337, making it unnecessary?
Edit: and what does a PMA as a "modified part" mean? Requires same paperwork as doing a splice (major repair--337), plus the AMOC?
Pictures multiple inspectors running screaming into woods, LOL.
DC

Re: A list of lift strut suppliers (updated 10 Nov 2007)

Dave:
I agree with you on the confusion factor. After a lot of thought and research on this I think the reason for the STC may be because the vendor replacement struts are not identical in construction to the factory struts (the streamline tubing size is larger).
I've run into this on the Superor Millenium A-65 cylinders. They require an STC because the head casting was improved and is not identical to the factory cylinder.

Garry Crookham
N5112M
Tulsa

Hey Garry thanks,

I think that would make sense to me if it didn't have PMA replacement part status but it does. According to McAnaul there is no need for an AMOC if it is a PMA approved replacement for the MA... part numbers in the AD. Otherwise it needs an AMOC according to him and he is the controlling office for AMOCs. BTW-FSDOs do not approve AMOCs, they are a channel for them to go to the McAnauls of the FAA**.

I am betting/guessing that the cylinders don't have a status as a PMA replacement part. The PMA replacements I normally use don't need STCs. The basis for this part's PMA certification as a replacement part is an STC (which seems odd to me). The cylinder kit that I found (which may not be the correct one, you say if its correct) has a PMA status but not a replacement part. Here's what I found;

cylinder PMA, not replacement parts, that's why stc/337;

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgpma.nsf/0/09389AD1880E85518525704D00544FA7?OpenDocument

Airframe's PMA is apparently a replacement part for MA-A815, that's why Andy says log entry only, what up with stc/337 I don't know;

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgpma.nsf/0/051C69D1E5C755FD86257387005E38EB?OpenDocument

Univair's PMA not a replacement part, that's why Univair needs an AMOC;

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgpma.nsf/0/E499064513487AC8852570500056BA9B?OpenDocument

I am still perplexed just showing you what I see, maybe it will lead to someting.
.
Thanks, Dave.



**§ 39.19 May I address the unsafe condition in a way other than that set out in the airworthiness directive?
Yes, anyone may propose to FAA an alternative method of compliance or a change in the compliance time, if the proposal provides an acceptable level of safety. Unless FAA authorizes otherwise, send your proposal to your principal inspector. Include the specific actions you are proposing to address the unsafe condition. The principal inspector may add comments and will send your request to the manager of the office identified in the airworthiness directive (manager). You may send a copy to the manager at the same time you send it to the principal inspector. If you do not have a principal inspector send your proposal directly to the manager. You may use the alternative you propose only if the manager approves it.

[flyguy]

Re: A list of lift strut suppliers (updated 10 Nov 2007)

8110.42B
1.4a
Also PMA may approve the production of parts from a supplemental type certificate (STC). PMA applies to most replacement and modification parts. Only use an STC for the approval of parts that constitute a major change to the product.

Talk about abusing the English language. I think "major change" is the operative word here.

So far haven't seen anything that directly indicates what paperwork process is required for installing a PMA (ed) part. Still searching.
DC

[Garry Crookham]

Re: A list of lift strut suppliers (updated 10 Nov 2007)

Dave:
I agree with you on the confusion factor. After a lot of thought and research on this I think the reason for the STC may be because the vendor replacement struts are not identical in construction to the factory struts (the streamline tubing size is larger).
I've run into this on the Superor Millenium A-65 cylinders. They require an STC because the head casting was improved and is not identical to the factory cylinder.

Garry Crookham
N5112M
Tulsa

[flyguy]

Re: A list of lift strut suppliers (updated 10 Nov 2007)

Strange.

If there sre FAA instructions/documents that detail the paperwork steps required to install a PMA part, then that is what needs to be done. Nothing else. No matter what anyone "says." If not, we are all sc---ed because then it becomes a matter of opinion. (Substitute the word judgement if you want to be nice.) So the question is: what does FAA documentation (FARs?) say about the paperwork for PMA parts?
Meantime I will look it up myself. Y'all have piqued my curiosity.
DC

Re: A list of lift strut suppliers (updated 10 Nov 2007)

Good info on the STC. I have the Airframe struts and thought I was going to have to file the 337. Thanks Dave for asking the question.

Gary, your welcome, sorry I wasn't better at scrubbing the answer.

I am lost now on this whole issue. A PMA replacement part that meets the AD terminating action requirement according to the office controlling the AD but also needs an STC (and no 337) according to the manufacturer, how does that make sense? I give up.

Dave

Re: A list of lift strut suppliers (updated 10 Nov 2007)

Terry,

This is why in red below, correct? STCs are only issued for major alterations so they are by definition a major alteration and require a 337.

§ 21.113 Requirement of supplemental type certificate.
Any person who alters a product by introducing a major change in type design, not great enough to require a new application for a type certificate under §21.19, shall apply to the Administrator for a supplemental type certificate, except that the holder of a type certificate for the product may apply for amendment of the original type certificate. The application must be made in a form and manner prescribed by the Administrator.


Dave

[barnstmr]

Re: A list of lift strut suppliers (updated 10 Nov 2007)

Levi,
I am not trying to be critical, but you are incorrect. All STCs require a 337. Not a big deal, because the STC is the "approved" data that allows an IA to sign off on block 3 of the 337. I recommend anyone using the Airframes Inc struts be aware of this and complete the 337 paperwork. Otherwise your airplane's records will have a gap that could come back and bite you someday.
Respectfully -

[Gary Snell]

Re: A list of lift strut suppliers (updated 10 Nov 2007)

Good info on the STC. I have the Airframe struts and thought I was going to have to file the 337. Thanks Dave for asking the question.

Re: A list of lift strut suppliers (updated 10 Nov 2007)

Drude,
A 337 is used when you make a major alteration or repair to any structure on an a/c. For example, if you weld on STC'd float fittings you have altered the structure of the airframe. Since your simply replacing parts here the 337 is not required. The STC is just there to cover the AD.Hope this clears it up for you.

Regards,
Levi

Ok, I see. I am assuming (always bad) that if there was an STC it involved some major alteration but it does not have to be. So I see that part now.

But it sounds like I could blow off the STC if I chose too and just go with the approved replacement part number if I wanted to as A. McAnaul suggested.

Re: A list of lift strut suppliers (updated 10 Nov 2007)

David,
Did Mr. McAnaul mention anything about issuing the AMOC for Wag Aero struts? I sent an e-mail to Wag-Aero asking if they had any news about getting it and they said they had been calling for Mr. McAnaul for the last 3 days with no response. Wag Aero is going to check into it. Hope this does not hold things up for Wag Aero.
Buell

Didn't mention anything about that but he was in a big hurry.

[levi907]

Re: A list of lift strut suppliers (updated 10 Nov 2007)

Drude,
A 337 is used when you make a major alteration or repair to any structure on an a/c. For example, if you weld on STC'd float fittings you have altered the structure of the airframe. Since your simply replacing parts here the 337 is not required. The STC is just there to cover the AD.Hope this clears it up for you.

Regards,
Levi

[Buell Powell]

Re: A list of lift strut suppliers (updated 10 Nov 2007)

David,
Did Mr. McAnaul mention anything about issuing the AMOC for Wag Aero struts? I sent an e-mail to Wag-Aero asking if they had any news about getting it and they said they had been calling for Mr. McAnaul for the last 3 days with no response. Wag Aero is going to check into it. Hope this does not hold things up for Wag Aero.
Buell